was a corporal with Prince George's CountyDepartment of Corrections ("PGDOC").2. Corporal R. D. was an officer with PGDOC.3. R. W. was a pretrial detainee being housed by PGDOC.

The Charge

4. On or about June 29, 2008, in the District of Maryland, the defendant,

ANTHONY McINTOSH,

while acting under color of law, willfully deprived R. W. of his right, protected and secured by theConstitution and the laws of the United States, to due process of law, which includes a pretrialdetainee's right to be free from a correctional officer's deliberate indifference to his serious medicalneeds. Specifically, defendant

McINTOSH

discovered R. W. in his cell, unresponsive and in

Case 8:12-cr-00039-JFM Document 1 Filed 01/25/12 Page 1 of 5

apparent need of emergency medical care, and walked away without providing medical care ornotifying PGDOC personnel of the emergency, thereby acting with deliberate indifference to asubstantial risk of harm to R. W., and resulting in bodily injury to, and the death of, R. W.18 U.S.C.

S

2422

Case 8:12-cr-00039-JFM Document 1 Filed 01/25/12 Page 2 of 5

COUNT TWOThe Orand Jury for the District of Maryland further charges that:1. Paragraphs 1through 3 of Count One are incorporated here.2. On or about June 29, 2008, in the District of Maryland, the defendant,

ANTHONY McINTOSH,

acting in relation to and in contemplation of a matter within the jurisdiction of the Federal BureauofInvestigation (FBI), an agency of the United States, knowingly concealed, covered up, falsified,and made a false entry in a record and document with the intent to impede, obstruct, and influencethe investigation and proper administration of the matter within the jurisdiction of a federal agency,namely the FBI, in that defendant